ML13189A057

G20130174 - Micheal Mulligan 2.206 Petition Transcript of 6/11/13 Teleconference Safety Relief Valves at Pilgrim Nuclear Power Station

ML13189A057
Person / Time
Site:	Pilgrim
Issue date:	06/11/2013
From:	Guzman R V Plant Licensing Branch 1
To:
Guzman R V
References
2.206, G20130174, NRC-004, TAC ME0927
Download: ML13189A057 (44)

Text

Official Transcript of Proceedings

NUCLEAR REGULATORY COMMISSION

Title: 10 CFR 2.206 Petition Review Board RE: Pilgrim Nuclear Power Station

Docket Number: (n/a)

Location: teleconference

Date: Tuesday, June 11, 2013

Work Order No.: NRC-004 Pages 1-41

Edited by Richard V. Guzman, NRC Petition Manager

NEAL R. GROSS AND CO., INC. Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.

Washington, D.C. 20005 (202) 234-4433

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C. 20005-3701 www.nealrgross.com 1 UNITED STATES OF AMERICA 1 NUCLEAR REGULATORY COMMISSION 2 + + + + +

3 10 CFR 2.206 PETITION REVIEW BOARD (PRB) 4 CONFERENCE CALL 5 RE 6 PILGRIM NUCLEAR POWER STATION 7 + + + + +

8 TUESDAY 9 JUNE 11, 2013 10 + + + + +

11 The conference call was held, Joe 12 Giitter, Chairperson of the Petition Review Board, 13 presiding.

14 15 PETITIONER: MICHAEL MULLIGAN 16 17 PETITION REVIEW BOARD MEMBERS 18 JOE GIITTER, Director, Division of Risk Assessment 19 in the Office of Nuclear Reactor 20 Regulation 21 RICHARD GUZMAN, Petition Manager for 2.206 petition 22 EMILY MONTEITH, Office of General Counsel 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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C. 20005-3701 www.nealrgross.com 2 NRC HEADQUARTERS STAFF 1 LEE BANIC, Petition Coordinator, Division of Policy 2 and Rulemaking, NRR 3 JOHN BILLERBECK, Component Performance and Testing 4 Branch, NRR 5 MUHAMMAD RAZZAQUE, Reactor Systems Branch, NRR 6 7 NRC REGION I OFFICE 8 FRED BOWER 9 10 ALSO PRESENT 11 JOSEPH LYNCH, Entergy 12 13 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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C. 20005-3701 www.nealrgross.com 3 P-R-O-C-E-E-D-I-N-G-S 1 (3:06 p.m.)

2 MS. RIVERA: Good afternoon. I would 3 like to thank everybody for attending the 4 teleconference.

5 My name is Alison Rivera, and I am the 6 Facilitator for this teleconference. My role is to 7 help ensure today's teleconference is informative and 8 productive.

9 The purpose of today's teleconference is 10 to allow the Petitioner, Mr. Michael Mulligan, to 11 address the Petition Review Board, or PRB, regarding 12 a 2.206 petition dated March 7, 2013, as supplemented 13 by emails dated March 20th and April 5, 2013, 14 regarding his concerns with safety relief valves at 15 Pilgrim Nuclear Power Station.

16 This teleconference is scheduled for one 17 hour1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br />, from 3:00 to 4:00 p.m., Eastern Time. It is 18 being recorded by the NRC Operations Center, and will 19 be transcribed by a court reporter.

20 The transcript will become a supplement 21 to the petition. Prior to placing the transcript in 22 ADAMS, the PRB will review it to ensure that it does 23 not contain any allegations or sensitive information.

24 For those dialing in to this 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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C. 20005-3701 www.nealrgross.com 4 teleconference, please remember to mute your phone to 1 minimize any background noise or distraction. If you 2 do not have a mute button, this can be done by 3 pressing the keys *6. To unmute, you will press *6 4 again. 5 I'd like to emphasize that we each need 6 to speak clearly and loudly, to make sure that the 7 court reporter can accurately transcribe the 8 teleconference.

9 If you do have something that you would 10 like to say, please first state your name for the 11 record. 12 Now, I would like to have the NRC meeting 13 participants to introduce themselves. I ask that all 14 of the participants clearly state for the record your 15 name, your position, and your organization.

16 I will start with myself, and then turn 17 it over to the other NRC participants here in the 18 room. 19 My name is Alison Rivera, and I am a 20 Technical Assistant for the Division of 21 Intergovernmental Liaison and Rulemaking, in the 22 Office of Federal and State Materials and 23 Environmental Management Programs.

24 CHAIR GIITTER: Okay. I'm Joe Giitter, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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C. 20005-3701 www.nealrgross.com 5 I'm the Director of the Division of Risk Assessment, 1 in the Office of Nuclear Reactor Regulations.

2 MR. BILLERBECK: This is John Billerbeck.

3 I'm a Mechanical Engineer in the Division of 4 Engineering in NRR.

5 MR. BANIC: Lee Banic, Petition 6 Coordinator, NRR.

7 MR. GUZMAN: Rich Guzman. I'm a Senior 8 Project Manager in the Division of Operating Reactor 9 Licensing, in the Office of NRR.

10 MS. RIVERA: That completes the 11 introductions of the NRC staff in this room. At this 12 time, are there any NRC participants from 13 Headquarters on the phone?

14 MR. RAZZAQUE: This is Mohammed Razzaque, 15 from Reactor Systems Branch, NRR.

16 MS. MONTIETH: Emily Montieth, Office of 17 General Counsel.

18 MS. RIVERA: Are there any NRC 19 participants from the regional offices on the phone?

20 MR. BOWER: Yes, this is Fred Bower. I'm 21 an Acting Branch Chief from Region 1.

22 MS. RIVERA: At this time, will the 23 representatives for Entergy Nuclear Operations, 24 Incorporated, Licensee for program, introduce 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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C. 20005-3701 www.nealrgross.com 6 themselves?

1 MR. LYNCH: This is Joe Lynch, Licensing 2 Manager, Pilgrim Station.

3 MS. RIVERA: Mr. Mulligan, would you 4 please introduce yourself for the record?

5 MR. MULLIGAN: I'm Mike Mulligan. I'm a 6 whistle blower. I was in the Navy on an experimental 7 pass protect submarine. I worked as a Reactor 8 Operator for a number of years, and I've worked at a 9 nuclear power plant.

10 Thank you.

11 MS. RIVERA: Thank you.

12 Are there any other, such as members of 13 the public, on the phone?

14 And, for our court reporter, can you also 15 please state your name?

16 COURT REPORTER: This is Sam Wojack. I'm 17 the court reporter.

18 MS. RIVERA: Before we begin, I'd like to 19 first share some general background on the 2.206 20 process. 21 Section 2.206 of Title X of the Code of 22 Federal Regulations, describes the petition process, 23 the primary mechanism for the public to request 24 enforcement action by the NRC in a public process.

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C. 20005-3701 www.nealrgross.com 7 This process permits anyone to petition NRC to take 1 enforcement-type action related to NRC licensees or 2 license activities.

3 Depending on the results of this 4 evaluation, NRC could modify, suspend, or revoke an 5 NRC issued license, or take any other appropriate 6 enforcement action to resolve the problem.

7 The NRC staff guidance for the 8 disposition of a 2.206 petition request is in 9 Management Directive 8.11, which is publicly 10 available.

11 Again, the purpose of today's 12 teleconference is to give the Petitioner an 13 opportunity to provide any additional support for the 14 petition, in light of the Petition Review Board's 15 initial recommendation.

16 This teleconference is not a hearing, nor 17 is it an opportunity for the Petitioner to question 18 or examine the PRB on the merits or the issues 19 presented in the petition request.

20 No decisions regarding the merits of this 21 petition will be made at this teleconference.

22 Following this teleconference, the 23 Petition Review Board will conduct its internal 24 deliberations. The outcome of these internal 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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C. 20005-3701 www.nealrgross.com 8 deliberations will then be discussed with the 1 Petitioner.

2 The Petition Review Board, typically, 3 consists of a chairman, usually a manager at the 4 Senior Executive Service level at the NRC. It has a 5 petition manager and other members of the Board, as 6 determined by the NRC staff, based on the content of 7 the information in the petition request.

8 As described in our process, the NRC 9 staff may ask clarifying questions in order to better 10 understand the Petitioner's presentation, and to 11 reach a reasoned decision whether to accept or reject 12 the Petitioner's request for review under the 2.206 13 process. 14 Also, as described in our process, the 15 Licensees have been invited to participate in today's 16 teleconference, to ensure that they understand the 17 concerns about their facility or activity.

18 While the Licensees may also ask 19 questions to clarify the issues raised by the 20 Petitioner, I would like to stress that the Licensees 21 are not a part of the PRB's decision-making process.

22 I will now turn the teleconference over 23 to Joe Giitter, the PRB Chairman, who will discuss 24 the specific petition under consideration.

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C. 20005-3701 www.nealrgross.com 9 CHAIR GIITTER: Okay, thank you, Alison.

1 I would like to begin by summarizing the 2 PRB's understanding of the scope of the petition 3 under consideration, and described the NRC's 4 activities to date.

5 On March, 2013, Mr. Mulligan submitted to 6 the NRC a petition on 2.206 regarding concerns with 7 the safety relief valves, or SRVs, at the Pilgrim 8 Nuclear Power Station.

9 In his petition request, Mr. Mulligan 10 requests that the NRC immediately shut down Pilgrim 11 Nuclear Station on the basis of the Licensee is 12 operating the plant in an unsafe condition with 13 defective or inoperable safety relief valves.

14 The Petitioner also indicates that 15 Entergy is incapable of maintaining safety and 16 quality of the plant. In addition, Petitioner 17 requests the NRC to not allow the Pilgrim Plant to 18 restart following shutdown until they understand past 19 failure mechanisms of the defective SRVs at Pilgrim.

20 As support for this request, Mr. Mulligan 21 states, in short, that the repeated nature of the 22 failure of the SRVs at Pilgrim demonstrates that 23 Entergy does not understand the mechanism of the 24 failure and that defective or inoperable SRVs at a 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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C. 20005-3701 www.nealrgross.com 10 nuclear power plant is unsafe.

1 Mr. Mulligan also states that the NRC is 2 allowing the plant to operate with unsafe SRVs until 3 the next refueling outage, and is covering up an 4 unsafe condition at Pilgrim.

5 Mr. Mulligan requests an investigation by 6 the Office of the Inspector General for his concern.

7 Now, I would like to talk about what NRC 8 has done to date on this.

9 On March 14, 2013, the Petition Manager 10 contacted the Petitioner to discuss the 10 CFR 2.206 11 process and to offer the Petitioner an opportunity to 12 address the PRB by phone or in person.

13 The Petitioner requested to address the 14 PRB by phone, prior to its internal meeting to make 15 the initial recommendation to either accept or reject 16 the petition for review.

17 On April 11, 2013, Mr. Mulligan addressed 18 the PRB via teleconference. The PRB then held its 19 internal PRB meeting on May 6, 2013, and on May 22, 20 2013, Mr. Mulligan was informed of the PRB's initial 21 recommendation regarding the petition, which is to 22 reject the petition for review, because in accordance 23 with Management Directive 8.11 Petitioner did not 24 provide sufficient facts, or any element of support, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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C. 20005-3701 www.nealrgross.com 11 beyond the basic assertion for the inquiry.

1 In addition, the PRB notes that the 2 Petitioner did not identify a violation of an NRC 3 requirement, or did Petitioner provide significant 4 new information to warrant the request of enforcement 5 action. 6 As support for its initial 7 recommendation, the PRB notes that the Licensee's 8 operability evaluation for SRVs that have leaked at 9 Pilgrim have been reviewed by the NRC inspectors, and 10 determined to be adequately justified. The Licensee 11 has also complied with the applicable tech specs, and 12 has demonstrated that SRVs are monitored and 13 maintained in a condition that ensures that they will 14 perform their safety function.

15 Additionally, the NRC staff continues to 16 monitor and collect operating experience on SRV 17 leakage problems. While the staff acknowledges that 18 industry has seen, and is investigating leaking SRVs 19 of this specific design, the NRC staff's evaluation 20 no industry operational data to date indicates that 21 the specific SRV model or design at Pilgrim poses a 22 real significant safety concern.

23 As a reminder for the phone participants, 24 please identify yourself if you make any remarks, as 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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C. 20005-3701 www.nealrgross.com 12 this will help us in the preparation of the meeting 1 transcript that will be made publicly available.

2 Thank you.

3 Mr. Mulligan, I'll now turn it over to 4 you, to allow you to provide any information you 5 believe the PRB should consider as part of its 6 decision.

7 MR. MULLIGAN: Okay. You talked about an 8 allegation that you were going to submit, an 9 allegation note or something. What was that about?

10 I'm just curious.

11 MS. RIVERA: The PRB will review the 12 transcript to ensure that there is no allegation with 13 sensitive information.

14 MR. MULLIGAN: Okay, thank you.

15 I will just say that, you know, like I've 16 always been talking about the NRC kind of says I have 17 no proof about the system as far as the access to the 18 information is zilch, and you give LERs, you give 19 inaccurate, falsified information to the public as 20 far as disclosures and stuff like that.

21 So, how can somebody like me have 22 confidence in the NRC doing their job?

23 Here's a June 11th Forbes article on San 24 Onofre, and southern California citizens problems 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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C. 20005-3701 www.nealrgross.com 13with their entire nuclear energy sector. So, a 1 nuclear energy sector has taken a blow now that 2 Southern California Edison has decided to permanently 3 close this troubled nuclear plant. Safety is a key 4 concern. So is honesty and transparency.

5 So, you know, you can take -- you guys 6 talk about risk, this doesn't have any risk and stuff 7 like that, and I'm telling you this has enormous risk 8 for the community and you guys.

9 You know, if you keep going on in this 10 direction, where, you know, a dual plant like San 11 Onofre, you know, we get the feeling that the NRC is 12 not enforcing their regulations correctly, and their 13 perceptions of what the regulations state is so 14 grossly obscene that, you know, we mistrust the 15 agency. I mean, that's a risk of a different sort, 16 that you don't even take into consideration.

17 And, this risk business, as far as giving 18 me the information, you know, as far as what is going 19 on with those valves, seeing the, you know, internal 20 documents and stuff like that, that is the same as 21 San Onofre had at its deepest core. You guys can 22 hide your information away from the public, and you 23 can have these special interpretations of rules and 24 regulations, as far as, you know, not having a proper 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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C. 20005-3701 www.nealrgross.com 14 license amendment request and stuff like that, you 1 can bend the rules, and stuff like that, you know, 2 that's atrocious to think that that -- you know, all 3 you guys deal with is the risk associated with, you 4 know, as far as these engineers' calculations nobody 5 can understand.

6 And, you don't look at the holistic risk, 7 as far as your behavior, how we, the public, see 8 this, and what garbage you've got in your document 9 and stuff like that that's the essence of, you know, 10 I talk about the tree-wise monkey architecture of 11 Federal rules. I would include the way you interpret 12 things, you know, the see no evil, hear no evil, 13 speak no evil, the idea that you interpret things 14 behind the scenes that nobody can make sure that you 15 are telling the truth and disclosing everything, and 16 all that sort of stuff.

17 And, that's what I'm talking about.

18 That's what we are seeing in front of us, you know, a 19 Pilgrim plant here, they've had a lot of protests, a 20 lot of towns, you know, have given their hope as far 21 as wanting to shut that down, and, evidently, nobody 22 feels, you know, with San Onofre and a whole bunch of 23 other events everybody feels nervous about disclosing 24 things. And, you know, you keep your things in your 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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C. 20005-3701 www.nealrgross.com 15 desk, and I mean that seems to be what's going on 1 here. The more you get frightened about events 2 happening in front of us, the more you hide things, 3 and the more destructive it's going to be, as far as 4 hiding events, and not taking care of these things 5 right, and turning off the public in ways.

6 So, you know, the new LER, I forget what 7 the most recent one, is startling, things that were 8 disclosed in that. And, of course, I put this to 9 2.206 before the LER came in, was written up.

10 Anyways, I get a joke out of the 11 Frankenstein Pilgrim SRV valve 3B, in an inspection 12 report of 2013, 00 May 8th, the inspectors observed a 13 plant shutdown on January 20, after operators had 14 identified significant leakage on SRV 3B pilot valve.

15 First stage temperature indicated a temperature 16 greater than 35 degrees. This exceeded the limits in 17 their procedures, and required the operating crew to 18 declare SRV 3B inoperable. And, you consequently 19 shut down and stuff like that.

20 And, you either repaired it or replaced 21 it, but, certainly, you must have tested it. And 22 then, you know, so on January 20th, January, 23 February, I don't know, two, three weeks later on, 24 operators responded to further shut down the plant.

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C. 20005-3701 www.nealrgross.com 16They started it back up, and on February 3rd 1 operators responded and affirmed indications of pilot 2 leakage on SRV 3B, following its repair and forced 3 outage 1906. Pilgrim remained at 80 percent power 4 until Blizzard Nemo took the plant down.

5 And so, you know, this is atrocious 6 behavior, that's one example, you know. You so-7 called fixed the valve, and, I mean, you know, is it 8 risky as far an engineering calculation on the 9 relative work on the component, involved with the 10 component, and stuff like that, do you guys deal with 11 risk? Or, is it risky, the actual behavior or 12 Entergy not to be able to have a leak, fix it, and 13 with days of starting up the valve starts leaking 14 again, and then they are forced to have a power 15 restriction and stuff like that.

16 So, you guys interpret this as there's no 17 safety issues, and what you can see over the period 18 when they purchased these valves, and stuff like 19 that, it's just atrocious utility and NRC behavior, 20 as far as, you know, engineering quality, and, you 21 know, you know what's going on with your plant, and 22 you have the tools in front of you that you could 23 quickly repair it. You know, this risk business is 24 an excuse to do nothing, and that's how this turns 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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C. 20005-3701 www.nealrgross.com 17 out. 1 This risk business and calculation is an 2 excuse to do nothing, and it's not an excuse to pay 3 attention to our plant. I mean, it's not a tool that 4 forces you to pay attention to your plant, and 5 purchase the quality of valve that is necessary and 6 stuff, and to repair it correctly, and test it. You 7 know, like this business here, it was started up and 8 it leaked again. And, this isn't the first time.

9 When they purchased them brand new valves 10 and put them in for the first time, they had leaks 11 within weeks of starting up again. Can you imagine 12 that, how that looks, as far as people like me 13 outside, the way we see this. You know, you guys 14 want the most important valve components in the 15 nuclear plant, and you can't figure out the quality 16 that is necessary for their duty, and they start 17 failing within two weeks, the new valves start 18 failing within two weeks. And then, you people have 19 the gall to come back and say, oh, well, this doesn't 20 meet any of our -- this is all safe, and this is 21 real good stuff, everything is okay.

22 Even to this day, even to this day with 23 two shutdowns over these valves, you are heading for 24 a third shutdown, you have an association of power 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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C. 20005-3701 www.nealrgross.com 18 restrictions and stuff like that, almost three 1 shutdowns and six or eight power restrictions at 2 different times and all that sort of stuff.

3 And, the last LER states that we still 4 don't know what's wrong with those valves, and we are 5 doing further investigation. Is that what nuclear 6 power has come to, as far as, you know, you guys 7 don't have the sense of quality and expertise and 8 honesty to deal with these things relatively 9 immediately, and the analysis gives you the excuse 10 that nothing ever matters, that we can run these 11 things into the ground, into the dirt.

12 I mean, you know, most of the public 13 doesn't really understand what's going on here, but I 14 do, and you do, too. And, allowing this stuff to go 15 on here, and somebody not raising a stink is 16 astonishing, especially, within the NRC.

17 I'm going to go back to the first LER for 18 a few comments there. At this time, the most -- this 19 is the first LER, LER 2011 007-00, right? At this 20 time, the most probably root cause are problems 21 during the initial manufacturing and their assembly 22 of the pilot at the Target Rock prior to installation 23 at the site.

24 CHAIR GIITTER: Could you restate that?

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C. 20005-3701 www.nealrgross.com 19 MR. MULLIGAN: At the time, the most 1 probable root cause were problems during the initial 2 manufacturing or assembly of the pilot at the Target 3 Rock prior to installation on the site.

4 Wile Labs, Target Rock and Entergy are 5 looking into these problems.

6 The identified condition, is a leaking 7 SRV pilot, based on the only pilot -- you know, 8 you've got to say this, what this is, the report 9 date, the event date, 12/26, right, 12/26, yes, the 10 pilot leaks, and this is what I'm talking about. This 11 is gross falsification of Federal documents. It's 12 gross falsification of Federal documents by NRC, by 13 Entergy, and the NRC doesn't call them on it.

14 Based on the review of the data, the only 15 pilot to exhibit leakage is RV --

16 MS. RIVERA: Mr. Mulligan?

17 MR. MULLIGAN: Yes.

18 MS. RIVERA: This is Alison Rivera. We 19 have a question over here about your previous 20 statement, trying to figure out if that's an 21 additional allegation.

22 MR. MULLIGAN: Yes, it is.

23 CHAIR GIITTER: Could you, specifically, 24 state the allegation again, Mr. Mulligan?

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C. 20005-3701 www.nealrgross.com 20 MR. MULLIGAN: Okay, based on the plant 1 data, the only -- "The only pilot valve that exhibits 2 signs of leakage is RV 203-3B." 3 And, let me see if I can -- the last LER 4 indicates that within weeks of starting up the plant 5 they had a leak -- they had a leak on a valve, and 6 then a month before the first LER they had another 7 leak on it.

8 And, when I get to that LER, I'll 9 identify that, the time frame.

10 CHAIR GIITTER: Okay. Could you just 11 restate the allegation again? I'm not sure I got 12 everything.

13 MR. MULLIGAN: Okay. The LER that I'm 14 talking about, 2007 007-00 it quotes right here, "The 15 only pilot valve to exhibit signs of leakage is RV 16 2003-3." 2003-3, RV 2003-3B.

17 "The only pilot valve to exhibit signs of 18 leakage is RV 2003-3," and they had two prior leaks 19 that they didn't disclose in this LER.

20 You got it?

21 CHAIR GIITTER: Yes, the LER was 2007-22 007? 23 MR. MULLIGAN: 2011.

24 CHAIR GIITTER: 2011, I'm sorry.

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C. 20005-3701 www.nealrgross.com 21 MR. MULLIGAN: So, this guy is -- the 1 event date is 12/26/2011 and two prior events before 2 that -- there was two prior events before that, that 3 they had leaks that they didn't disclose, that they 4 later disclosed on the most recent LER.

5 Okay? 6 CHAIR GIITTER: Thank you.

7 MR. MULLIGAN: And, this is another one.

8 This is another allegation. Because the leakage 9 established by procedure did not affect the SRV set 10 pressure, or capacity, the SRV would have been able 11 to respond if needed to meet core cooling or reactor 12 vessel over pressure, over pressure detection 13 function.

14 And, the most recent LER says that there 15 was a leakage effect of the SRV open set point. And 16 so, I mean, the idea that they are saying it did not 17 affect the SRV set pressure or capacity set pressure, 18 you have to meet set pressure.

19 So, and then later on, because of the 20 leakage you did have an SRV that exceeded its plus or 21 minus 3 percent opening set point level. And, if you 22 would have known about that, I believe it was 3.8, if 23 you would have known about that they would have been 24 required to shut the plant down.

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C. 20005-3701 www.nealrgross.com 22 And so, you now, you are sitting here --

1 you know, he makes a kind of a simple statement that 2 the procedure did not affect the SRV set point 3 pressure. So, what is thinking of these guys, you 4 know? Okay, we've got leaks here and stuff like 5 that. If it hasn't reached its set -- it hasn't been 6 inaccurate yet, but, you know, is the engineers going 7 down there anticipating the future, can we have 8 opening set points inaccuracy problems that we can't 9 see and stuff like that. We could, essentially, have 10 a set of SRVs that would not be able to reach -- be 11 at their accuracy level, plus or minus 3 percent, and 12 stuff like that.

13 So, you know, the idea that these guys 14 can say to themselves do an analysis and say, oh, and 15 one of the issues we could have in the future with 16 our crazy SRVs that keep malfunctioning on us, is we 17 could have an inaccurate opening of an SRV. We could 18 have an inaccurate opening of an SRV for an over 19 pressure condition caused by the leak. I mean, is 20 anybody thinking about these things, about how set 21 pressure could become inaccurate?

22 And then you say to yourself, well, do 23 they even test for set pressure on all these leaking 24 valves that they had, and stuff like that. Do they 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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C. 20005-3701 www.nealrgross.com 23 check themselves and say, hey, we are going to do a 1 set -- an opening, with these defective leaking 2 valves we are going to do -- and, you know, we are 3 going to raise up questions to the valve opening and 4 see where it begins to open, and see if the leakage 5 has caused set pressure problems and stuff like that.

6 Is anybody doing that kind of stuff?

7 You know, so there's an issue that, you 8 know, they really assumed that the leaking wouldn't 9 cause any SRV set pressure problems in the future, 10 and, of course, we know that they did.

11 So, and here's another one with the 12 leaking -- the leaks that they didn't disclose.

13 There is no previous first-stage leakage occurring at 14 these safety relief valves since all four safety 15 relief valves were newly installed in May --

16 April/May, 2011, during refueling outage 18.

17 But, you know, they made the assertion in 18 Federal documents that there was no prior leakage, 19 and you know there's two other -- there's two other 20 leakages that, you know, I should have been, you 21 know, outsiders should have been notified. And, we 22 should have seen how inaccurate these safety relief 23 valves are, and how unreliable, and how incompetently 24 Entergy has dealt with the -- Entergy and Target Rock 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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C. 20005-3701 www.nealrgross.com 24 has dealt with these safety relief valves.

1 Now, just like San Onofre, if you hide 2 things it's going to be ten times worse when 3 something bad happens, instead of being open and out 4 front, and making, you know, people want to talk 5 about things, and making an effort to talk about 6 those issues, instead of just kind of -- you know, 7 hiding, you know, the politicians above us, Congress 8 and, you know, the hateful Republicans and all that 9 sort of stuff, they are going to vaporize us if we 10 open our mouths, or if we enforce regulation and 11 stuff like that. And so, I'll be quiet, you know, 12 see no evil, hear no evil, and speak no evil.

13 If you get into that San Onofre mindset, 14 that's more destructive than a meltdown, as far as 15 I'm concerned.

16 And, here's another one. However, the 17 industry has experienced leakage with other Target 18 rock model safety relief valves at other plants.

19 Other, you know, there's Entergy, how come they 20 didn't -- you know, it sounds like there was that 21 they admit in that last LER, the newest LER, that 22 there was a set of issues which are three-stage 23 Target Rock relief valves. Again, you know, taking 24 the narrow thing that, you know, maybe it's not an 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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C. 20005-3701 www.nealrgross.com 25 other model, you know, being this model isn't 1 leaking, or however they want to term it, but there 2 was leaks with three-stage Target Rock. However, the 3 industry has experienced leakage with other Target 4 rock model safety relief valves.

5 You know, they are saying that the three-6 stage relief valve, the three-stage doesn't have 7 leakage problems in the industry, when in reality 8 there was a host of Target Rock model safety relief 9 valves that were leaking, and it's not full 10 disclosure.

11 You know, how do you -- how do you -- you 12 know, if there was widespread issues in the industry 13 with three-stage safety relief valves, how is 14 outsiders, like a guy like me, supposed to, you know, 15 utilize it, if you guys don't want to, you know, deal 16 with your problems, it's just up to me to try and 17 figure out what's going on and trying to help you 18 guys do the right thing.

19 With these issues in the 2.206, I mean, 20 if you hide information on me, and stuff like that, 21 then it negates the 2.206 process. It makes me -- it 22 makes me -- I don't have any information. And, you 23 keep coming back at me that, you know, I don't have 24 any information, that type of thing, and stuff like 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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C. 20005-3701 www.nealrgross.com 26 that. 1 So, everybody feels comfortable that I 2 don't have any evidence. You know, is that because 3 there's no evidence, or is that because a whole ton 4 of evidence is being hidden from me. Those are 5 completely different things.

6 You know, the OE business, and all the 7 internal documents that Entergy has, the OE, you 8 know, safety relief temperature phenomenon at Target 9 Rock, and stuff like that, you know, it's all hidden 10 from me. It's all hidden from guys like me, and when 11 you do that you prevent a guy like me from stopping 12 you from doing the San Onofre, you know, as far as, 13 you know, harassing you, and making you slow down, 14 and making you do the right thing, and stuff like 15 that, you hide it. And that, in essence, causes 16 these big events where you end up losing the trust of 17 people around the plant, and you have to shut down 18 the plant, or the plant operation.

19 You know, and then we go into the -- I've 20 already talked about this, then we go into the 21 following, you know, this is the next -- this was the 22 update on that LER of 2011, Level 2, and, you know, 23 there was -- and it talks about all the different, 24 you know, testing and all that sort of stuff, like, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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C. 20005-3701 www.nealrgross.com 27you know, no big deal, everything is cool. We looked 1 over and we find no -- who was it, there was a whole 2 bunch of you guys involved, Southern Company, Wile 3 Labs, Entergy, and who else, there was another one, 4 and stuff, and you made a big deal over that first 5 LER, that first leak and stuff, and you had another 6 shutdown, another new shutdown with the NEMO 7 blizzard, with that bad valve, and then like I told 8 you, then you replaced the valve with a new, fully 9 tested valve, and within days it leaks up, it has 10 leaks again, just like when you installed that valve 11 for the first -- these valves for the first time, 12 within two weeks you have an indication of leakage.

13 You had, before the first shutdown you 14 had two leakages and stuff like that. This is 15 heightened, and in the NRC's mind this is right?

16 This is the right outcome to deny me a 2.206 because 17 I don't have enough evidence and stuff like that?

18 This is right, that you don't fix this thing?

19 I don't know, it's still up in the air as 20 far as what's causing all these shutdowns and stuff 21 like that, not only at Pilgrim, but other plants, and 22 stuff. It's right?

23 We are the United States of America, the 24 best country on the planet, and stuff like that, and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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C. 20005-3701 www.nealrgross.com 28 this doesn't reflect well on us at all as a 1 democracy, and the essence of being truthful, honest 2 to each other, especially, with these endeavors that 3 have a lot of energy in them and stuff like that.

4 It's wrong.

5 So, here we go. We have in the update, 6 no additional corrective actions are recommended on 7 the results of testing, inspection and evaluation of 8 the leaking pilot valve, by a three team of Wile 9 Labs, Target Rock and Entergy. You know, these 10 things -- you know, and then we talk about 10 CFR 21, 11 that for the first time in the industry it's ever 12 happened that the bellows had a crack in it, and we 13 don't know -- we are not clear whether that came from 14 a -- it came from directly from plant operation, you 15 know, they shut down, then they tested it, and then 16 up, or whether it was, certainly -- it was, 17 certainly, heading back to the plant, and then you 18 say that these valves, in an emergency, you know, can 19 operate between 250 to 500 times, you know, in a dire 20 accident, you know, the worst accident you can 21 imagine, no electricity and stuff like that.

22 And, you know, you've got this defect in 23 the bellows that, you know, nobody still -- and it's 24 just astonishing, you guys are educated, and you've 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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C. 20005-3701 www.nealrgross.com 29 got a whole bunch of processes and stuff like that, 1 and you can't -- it takes you years. I mean, the LER 2 process sounds like the engineer, it's not 3 engineering to engineer these documents to tell the 4 truth, it's giving them the excuse to hide it, you 5 know, we'll do another update, and we'll just ignore 6 it, and we'll falsify documents in front of you. And, 7 the NRC will, you know, hear no evil, see no evil, 8 and speak no evil.

9 They have a ton of rules, but they 10 interpret them in a special way that nobody can see 11 if they are doing it right. I just -- it's mind 12 boggling, when you consider how big this thing is.

13 You know, and you have the update, and however 14 industry has experienced leakage with other Target --

15 you know, however, the industry has experienced 16 leakage with other Target Rock model safety relief 17 valves at other plants. Why isn't there a thing, we 18 have -- let's be honest, you know, and up front, 19 instead of giving you a baloney sentence like that, 20 why couldn't they give a list of all the plants, you 21 know, all the plants that had problems with three-22 stage relief valves.

23 In the LER, they've got the three-stage 24 guys in there, you know, San Onofre again, how come 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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C. 20005-3701 www.nealrgross.com 30 nobody -- how come in that license amendment request, 1 put these three-stage guys in there, how come they 2 didn't talk about all the vulnerability of three-3 stage valves. How come they didn't talk about all 4 the leakages with three-stage Target Rock relief 5 valves in that LER. You know, how come, you know, 6 they quoted regulations business and all that sort of 7 stuff, you know, and happy land, these are new valves 8 replacing old valves, how come you never talk about, 9 you know, the thermability of these three-stage 10 valves, what problems there were in the industry, and 11 that type of thing.

12 How come -- is that all the documents, 13 you know, all the NRC's documents and LERs in the 14 industry, the happy land, this is the happy land 15 version of documentation, and we are the professional 16 class of incomplete and inaccurate Federal documents 17 and stuff like that. Is that what this -- is that 18 what's going on here with LERs in general and stuff 19 like that, or, you know, like for like processes and 20 stuff like that, is anybody going behind the scenes 21 and talking and interpreting these things in a way 22 for themselves, and not for what's in the interest of 23 our country.

24 That stuff, it asks so much of us, it 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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C. 20005-3701 www.nealrgross.com 31 asks so much of us to be better people, and so we'll 1 go to the new one. This is the guy that is kind of 2 interesting, you know. I did write my 2.206 before 3 this, right, and I did have my first transcript thing 4 there, so this is a new one. And, you know what it's 5 talking about, SRV 3B, safety relief valve declared 6 inoperable due to leakage and set point drift, right?

7 This guy is still going to say, at the end of it, 8 after all of this in the industry we still don't know 9 what's wrong with these safety relief valves. We are 10 still investigating it. Is that what we've come down 11 to, that it takes two years and you are still 12 investigating it? Is it going to be another ten 13 years before you come to a solution with this, and 14 you've become honest with people and stuff like that?

15 Do you know how dangerous this kind of 16 stuff is to you guys, you know, if an accident shows 17 up, and it turns off everybody, this is 18 extraordinarily dangerous stuff. You see the problem 19 we face if all of a sudden everyone has lost faith in 20 the NRC, and we start turning off these plants nilly-21 willy, you know, we lose a tremendous amount of 22 electricity, electrical capacity, because you guys 23 are mistrustful.

24 You say you follow the rules, and you 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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C. 20005-3701 www.nealrgross.com 32 create meticulously accurate documents, but you play 1 these document games and selective disclosures, and 2 you space these things for a date, you know, six 3 months down the line. Your fine LER is obscenely 4 inaccurate and falsified, and it's all staged to not 5 come up with a solution or accurately describe what's 6 going on. It's an excuse to delay fixing these 7 things and keeping a plant in operation, when they 8 shouldn't be in operation. It's an excuse for, you 9 know, Entergy, or any other plant in the United 10 States, you know, we've got a problem and we 11 shouldn't play these document dancing games whenever 12 we feel like it and stuff like that, and we can delay 13 admitting what's going on here for months.

14 Now, with Vermont Yankee with the safety 15 relief threaded seal business, you won't admit to it, 16 but you did the same thing. And so, then we go down, 17 automatic depressuring provides tanks for 18 interpreting the thermocoupling data and determine 19 valve operating, based in part on testing performed 20 by Target Rock. Can I see that? Can I see that --

21 can I talk to somebody in Target Rock and say, you 22 know, what is your indications when you have a 23 leaking relief valve, what is the failure rate of set 24 point inaccuracy problems, you know, about not 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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C. 20005-3701 www.nealrgross.com 33 lifting plus or minus three at the right pressure.

1 See, and remember, this is the guy that 2 you asked me the question about. So, as far as the 3 installation of RF2, oh, man, I'm getting all 4 excited, the installation in RF018 and prior to this 5 Pilgrim experience, minor second stage valve leakage 6 from SRV, RV203-3C. We know, from this one, too, 7 it's the first stage and the second stage, two 8 different components here. So, and, basically, you 9 know, you've got the inaccuracy problems, and then 10 you've got the bellows issues. You know, these 11 things are all broken up into little pieces with you 12 guys, and you see the happy tune side of it, and 13 stuff like that.

14 What happens if you put everything 15 together? Do you think the bellows thing was just a 16 coincidence? Do you think this whole cycle was just 17 a coincidence that just happened? Hey, you know, 18 almost three shutdowns and all these things, can you 19 imagine the money associated with this, with these 20 three shutdowns, three-day shutdowns, a million and a 21 half, maybe $2 million a day or more, and stuff like 22 that. Is this competency?

23 I don't understand how the CEO gets away 24 with this stuff, that he can have an organization 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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C. 20005-3701 www.nealrgross.com 34 that's so incompetent, and they can't see each other 1 that he is sabotaging the operation of this plant 2 because he's losing money on full-quality valves, you 3 know, in a host of ways. I can't understand, I hope 4 this isn't going on throughout the whole fleet, where 5 these guys are so incompetent and, you know, 6 reckless, as far as with money, with Entergy, I don't 7 see how they get away with it.

8 So, we are going to get done reading that 9 Pilgrim experience minus second-stage pilot valve 10 leakage from SRV RV203-3C on May 18, 2011. That's 11 two weeks, wasn't anybody astonished, brand new 12 valves, this is a mature design of valves. We've had 13 these valves in the system for many decades, and two 14 weeks after installing brand new valves they start 15 leaking. 16 And then November 2nd, they start leaking 17 again and stuff like that, and nobody does nothing?

18 You know, no, it will go away, we'll just ignore it 19 and it will go away. Every time they have a 20 shutdown, or whatever stuff, we don't have to tell 21 anybody, and it will go away. We don't have to --

22 you know, all this my interest and stuff like that, 23 you'd think before they start it up they would have, 24 you know, said, oh, we found the problem, and it's 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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C. 20005-3701 www.nealrgross.com 35taken care of, fixed for sure this time. Would you 1 trust them, though, with falsifying documents like 2 they've done, and the NRC sitting back and playing, 3 what is that one, the wise monkey stuff.

4 So, November 25th and December 26th, 5 2011, the first two leaks, that was never disclosed 6 until this last -- you know, and then they -- I never 7 got to see this LER until the plant was shut down, 8 you know. Do you know what that stinks of? You guys 9 were structuring closure of this valve in a safe 10 shutdown, and stuff like that. Is that what was 11 going on here with Entergy is saying, well, we don't 12 want to admit this when the plant was in operation.

13 We don't want to, you know -- we probably have some 14 -- we don't have to disclose these things within a 15 certain amount of time, they just have to do it when 16 they feel like it, when it's convenient, when the 17 plant is in a safe condition, a shutdown condition, 18 and they won't be threatened by a shutdown, you know.

19 As I said, do we have to get in this 20 environment where everybody is so scared, you know, 21 the San Onofre shutdown, and a host of other threats 22 going on and stuff like that, and then pretty soon, 23 you know, they are pulling in the horns, and we come 24 in a dictatorship state, essentially, with releasing 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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C. 20005-3701 www.nealrgross.com 36information. The security causes us to close down, 1 to be like a -- not the great United States of 2 America, our country, we are with our legal systems 3 and all that sort of stuff, are we becoming something 4 that we shouldn't be, because we are fearful, and 5 because, you know, it has to -- you know, it becomes 6 a turmoil, and troubles like that, do we hinder to 7 our basic instincts, or do we come bigger than we 8 are, we have to be, we come bigger and better than we 9 normally are. Does our character ask us 10 or tell us into being more open? I don't feel I 11 should be closed, I try to be bigger than that. I've 12 got to be bigger in front of my family, in front of 13 my Nation, and I've got to set my sites to a standard 14 that purports to our Constitution, that this is the 15 ideals of our Constitution, openness, earnestness, 16 integrity, trustworthy, and I'm a man of my honor, or 17 a woman. 18 Or, do I fiddle around with these rules, 19 I twist them around, and, you know, we all think we 20 are following the rules, but the product is that we 21 are getting falsified and inaccurate information out 22 there. We sit back and be happy that we are 23 following the rules, and nobody can -- not outsiders 24 can really understand if you are following the rules, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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C. 20005-3701 www.nealrgross.com 37 or you are misinterpreting the rules and regulations 1 and stuff like that.

2 And, you know, it goes down to this thing 3 of character and honor and stuff. If you don't have 4 that, you know, I'd rather have character and honor 5 than rules, really, when you get down to it. I 6 believe you can be good people, and being good, and 7 honest, and transparent, and stuff like that, can 8 bail you out of a lot of trouble type of thing.

9 And, you know, fiddling around with 10 rules, and disclosures, and, you know, playing it 11 safe, you are asking for a disaster of enormous 12 magnitude, and it doesn't have to, necessarily, be a 13 core meltdown, it could be an integrity meltdown, 14 like at San Onofre.

15 So, with the condition potentially high, 16 here we go, condition potentially placed on all four 17 states SRV valves that were installed in RF018, how 18 come that ain't raising back the hairs on everybody's 19 head. This is common mode failure. It's diagnosed 20 and they don't know what's causing it, or they won't 21 admit it, is that what -- I mean, like I said, is 22 that what's going on here, they know what's going on 23 her but they just holding it for money reasons, not 24 to lay the blame disclosing what's going on here and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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C. 20005-3701 www.nealrgross.com 38 stuff. 1 I know I've got three minutes left.

2 You know, that bugs me, May 18, 2011, two 3 weeks after the start-up of brand new valves, and 4 November 22nd, then they lied about it on December 5 26th. They lied about it in documents. See, the 6 2.206 problem is supposed to give a guy like me the 7 ability to create transparency and change your mind, 8 change your hearts and minds and stuff like that.

9 That's what the 2.206 -- it's bigger -- I'm an idiot, 10 and I'm a peon and an ant, but it's supposed to be 11 something that is bigger than me, and bigger than 12 you, and it's supposed to be a tool of transparency, 13 where our Nation gets to see what's going on, and 14 give support to the ideals of what a great nation is, 15 and great character, and honor, and integrity.

16 That's what the 2.206 problem is.

17 And, the way this thing is instituted now 18 is that, it's a tool of the devil, and then we get to 19 talk about my deviation 3.8, if they would have seen 20 that, if they would have magically had the God's-eye 21 view of seeing that 3.8, they would have had to shut 22 down. 23 I know, these guys don't test it until 24 they are shut down, but there's a requirement if it 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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C. 20005-3701 www.nealrgross.com 39 goes past the 3.8 -- 3.0, you are supposed to shut 1 down, but you don't test it. It's mind boggling.

2 Additional corrective actions will be 3 implemented based on the results of testing, 4 inspection and evaluation of the first -- leaking 5 first stage from the 2B valve.

6 You know, the risk of operating the 7 valves, the risks of operating the SRV characterized 8 by increased chance, right? They had problems this 9 last time, you didn't know if the valve was open or 10 shut because they couldn't hear the noise monitor, or 11 the noise detector, acoustical detector, you know. I 12 don't know what that was all about.

13 But, having an inadvertent open SRV would 14 increase chance of valve failure to reclose. That's 15 important, but, you know, you guys don't talk about 16 putting an accurate set point pressure on it. They 17 maybe talk about -- talking about the set point 18 drift, and they don't even talk about -- you know, 19 you were quiet once it got back 3.0, we are supposed 20 to -- and then, you know, industry has experienced 21 numerous instances where SRV leakage has occurred at 22 other plants with other Target Rock three-stage 23 relief valves. I'd like to know what that means, 24 with other -- you know, so you could have other 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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C. 20005-3701 www.nealrgross.com 40 Target Rock model three-stage relief valves, I mean, 1 there's more than one model for three-stage relief 2 valves, you know.

3 But, here they start talking about, you 4 know, three-stage relief valves at Plant Hatch, and 5 other things, and then they start talking about the 6 three stage, you know. Oh, we've had other problems, 7 even that first LER talks to us about we have leakage 8 in that other valve, not the model we are using here 9 type of language, and now they are talking about, oh, 10 well, you know, here's a list of three-stage relief 11 valves that we've had.

12 You know, that whole thing, honesty, 13 integrity, and I'm a man of character type of thing, 14 you know, an organization, I never would write a bad 15 report, an organization never forces me to write a 16 bad or an inaccurate report, because I'm a man of 17 integrity. I will not tolerate that kind of business 18 type of thing.

19 And, I guess, you know, you know my 20 issues with the Navy rock that go shut down with the 21 weather instrumentation.

22 Yes, I'm done.

23 CHAIR GIITTER: Thank you, Mr. Mulligan.

24 At this time, does any staff here at 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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C. 20005-3701 www.nealrgross.com 41 Headquarters have any questions for Mr. Mulligan?

1 CHAIR GIITTER: Thank you. What about 2 the region?

3 MR. BOWER: None.

4 CHAIR GIITTER: Thank you.

5 Before I conclude the meeting -- well, we 6 don't have any members of the public, or we didn't, 7 so I just want to make sure there's no members of the 8 public on the bridge. Okay.

9 As stated in the opening, the purpose of 10 this meeting is not to provide an opportunity for the 11 Petitioner or the public to question or examine the 12 PRB regarding the merits of the petition request.

13 Mr. Mulligan, I thank you for taking time 14 to provide the NRC staff with verifying information 15 on the petition you submitted. The PRB plans to meet 16 internally, and discuss the matter one more time.

17 Before we close, does the court reporter 18 need any additional information for the meeting 19 transcript?

20 COURT REPORTER: No, I've got everything, 21 thanks. 22 CHAIR GIITTER: Thank you. With that, 23 the meeting is concluded, and we'll be terminating 24 the phone connection.

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C. 20005-3701 www.nealrgross.com 42 MR. MULLIGAN: And, thank you very much 1 for this opportunity.

2 CHAIR GIITTER: Okay, thank you, Mr.

3 Mulligan.

4 (Whereupon, the above-entitled matter was 5 concluded at 4:03 p.m.)

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